Practice Areas
Francis Fitzpatrick KC has a strong litigation and tax specialist advisory practice. He acts for financial institutions, blue-chip companies and private individuals and for UK and foreign governments.
He acts for corporates, multi-nationals, partnerships, HNWIs, HMRC and governments on all areas of direct and indirect tax. He has wide experience of commercial and ‘City’ transactions and litigation including: corporate finance, loan relationships, structured finance, partnerships, leasing, private equity, employment remuneration, infrastructure project funding, asset management, trusts, land development, shipping, cryptoassets, insurance, energy and energy infrastructure, intellectual property, cross-border transactions, transfer pricing and the operation of general and targeted anti-avoidance regimes (such as the unallowable purpose loan relationship rules and the GAAR). He also has especial expertise in international tax work, including digital taxes; exchange of information laws, double tax treaties, bi-lateral investment treaties, taxation of international performers and athletes.
Career
He has extensive litigation experience. In recent years this has included: banking; pharmaceuticals; shipping; air transport; energy; judicial review; double tax treaties; cryptoassets; information technology; HNWIs; employment status; loan relationships; capital allowances; intangible assets; R&D; transfer pricing; partnerships and LLPs; FX issues; professional negligence; crime; and alternative investment managers.
• Reid v HMRC [2025] (legal professional privilege and the iniquity exception)
• Syngenta Holdings Limited v HMRC [2024] UKFTT 998 (unallowable purpose rule)
• Stage One Creative Services Limited v HMRC [2024] (R&D)
• Muller UK and Ireland Group LLP and others v HMRC [2024] UKUT 27 (LLPs and intangible assets)
• Collins Construction Limited v HMRC [2024] UKFTT 951(R&D)